Privacy Policy

INTRODUCTION

PURPOSE OF THIS PRIVACY NOTICE

It is important that you read this privacy notice simultaneously with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to overrule them.

CONTROLLER

The Bwiz solutions is made up of different legal entities, details of which can be found here. This privacy notice is issued on behalf of the Bwiz solutions so when we mention “Bwiz solutions”, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the Bwiz solutions responsible for processing your data. We will let you know which entity will be the controller for your data when you purchase a product or service with us.

CONTACT DETAILS

Our full details are:

Full name of legal entity: Bwiz solutions Private Limited

Postal address: 207, 2nd Floor, Abhishree Adroit, Near Mansi Circle, Judges Bunglow road , Vastrapur, Ahmedabad , Gujarat 380015 INDIA

If you live in the EU, you have the right to make a complaint at any time to one of the national supervisory authorities that enforces data protection law, for example, the Information Commissioner’s Office (ICO) in the UK (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach a supervisory authority so please contact us in the first instance.

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

We reserve the right to modify this privacy policy and will inform you by updating this policy, so please check it from time to time, especially if you have ongoing dealings with us. It is important that the personal data we hold about you is precise and current. Please keep us informed if your personal data changes during your relationship with us.

THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. We cannot be responsible for the protection and privacy of any information which you provide while viewing such sites; such sites are not governed by this privacy statement. When you leave our website, we promote you to read the privacy policy of every website you visit.

2.  DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (unidentified data).

We may collect, use, store and transfer different kinds of individual data about you which we have grouped together follows:

• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Profile Data includes your interests, preferences, feedback and survey responses.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Usage Data includes information about how you use our website, products and services.
• Identity Data includes first name, middle name, last name, username or similar identifier and title
• Marketing and Communications Data includes your preferences in receiving marketing material from us.

We may also collect, use and share Aggregated Data such as fiscal, statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the proportion of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly recognize you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

Apart from industry-wide or governmental surveys where we are obliged to take part, and except while performing obligations pursuant to specific written contracts with clients, we do not normally collect any Special Categories of Personal Data about you.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3.  HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by phone, email or otherwise. This includes personal data you provide when you:
  • Apply online or otherwise for our products or services;
  • Contract to receive our services or provide services to us;
  • Read the online marketing information available on the Website, various micro sites powered by Bwiz solutions and landing pages sent through e-mails sent either on behalf of the Bwiz solutions or our clients;
  • Request marketing material to be sent to you;
  • Enter a promotion or survey;
  • Download our client’s white papers; or
  • Give us feedback.
• Automated technologies or interactions. As you interrelate with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
• Third parties or publicly available sources. We may receive personal data about you from various third parties events and in pursuant to entering into a contractual arrangement with third parties.

Technical Data from the following parties:

1. Analytics providers such as Google;
2. Affiliated marketing networks;
3. Search information providers
4. Digital portals
   • Contact and Transaction Data from providers of technical and delivery services. Identity and Contact Data from data brokers or aggregators
5. Identity and Contact Data from publicly available sources such as Companies House and the Electoral register, statutory authority websites.

4.  HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you or to perform other legal obligations,
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by Contacting us.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please Contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer	1. Identity 2. Contact	Performance of a contract with you
To process and deliver services and/or perform contractual obligations for you, including collecting and recovering money owed to us	1. Identity 2. Contact 3. Financial 4. Transaction 5. Marketing and Communications	Performance of a contract with you Necessary for our legitimate interests (to recover due to us)
To manage our relationship with you which will include: Notifying you about changes to our terms or privacy policy Asking you to leave a review or take a survey	1. Identity 2. Contact 3. Profile 4. Marketing and Communications	Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/ services)
To enable you to take part in a prize draw, competition or complete a survey	1. Identity 2. Contact 3. Profile 4. Usage 5. Marketing and Communications	Performance of a contract with you Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	1. Identity 2. Contact 3. Technic	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) Necessary to comply with a legal obligation Necessary to resolve disputes
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we provide to you	1. Identity 2. Contact 3. Profile 4. Usage 5. Marketing and Communications 6. Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences; provide audit record for consent;	1. Technical Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	1. Identity 2. Contact 3. Technical 4. Usage 5. Profile	Necessary for our legitimate interests (to develop our products/services and grow our business)
To send information/white papers/marketing material on behalf of our clients.	1. Identity 2. Contact 3. Technical 4. Usage 5. Profile	Necessary for our legitimate interests (business to business direct marketing activity on behalf of our clients Necessary to perform contractual or legal obligations.
To make suggestions and recommendations to you about goods or services that may be of interest to you	1. Identity 2. Contact 3. Technical 4. Usage 5. Profile	Necessary for our legitimate interests (to develop our products/services and grow our business)
To send information/white papers/marketing material on behalf of our clients.	1. Identity 2. Contact 3. Technical 4. Usage 5. Profile	Necessary for our legitimate interests (business to business direct marketing activity on behalf of our clients Necessary to perform contractual or legal obligations.

MARKETING AND PROMOTIONAL OFFERS FROM US

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

THIRD-PARTY MARKETING

We will get your express opt-in consent before we share any personal data received from you with any company outside the Bwiz solutions of companies for marketing purposes.

OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by Contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please refer policy.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5.  DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

• Internal Third Parties as set out in the Definitions.
• External Third Parties as set out in the Definitions.
• Third party sub-contractors who provide services for us and/or help to provide services to you.  In the event that we use sub-contractors who have access to your personal data, we ensure that there are strict contractual terms in place to ensure that they only process personal data to the extent that we instruct them to do so in writing and there are suitably worded confidentiality and data protection clauses in all such contracts
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6.  INTERNATIONAL TRANSFERS

We may share your personal data within the Bwiz solutions.

Currently, most/all personal data is held on our servers located in the India. Some personal data may also be held on servers in the US. Accordingly, personal data is held outside the EEA.

We ensure that your personal data is protected in line with EEA standards by requiring all our group companies to follow the same rules when processing your personal data. These rules are called “binding corporate rules”.

In addition, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented for all processing outside the EEA:

• where we use service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in the EEA; and/or
• where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar data protection to that afforded in the EEA.

7.  DATA SECURITY

We and our third party hosting partners have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8.  DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Under Indian law we will normally have to keep basic information about our customers and agency-type services (including Contact, Identity and Transaction Data) for 7 years after they cease being customers. In relation to contractual services this period may be extended to 15 years. [Thereafter, we will either destroy or return personal data to the client.]

In some circumstances you can ask us to delete your data: see the section below entitled “Your Legal Rights” for further information.

We may also anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9.  YOUR LEGAL RIGHTS

Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but

Information Technology
Policies and Procedures

If you have any questions related to Data Subject Access Rights under GDPR or CCPA, you can contact us through policies@bwizsolutions.com

Privacy Policy Overview
What Categories of Information We May Process
Sensitive Personal Information
How We Collect or Create Information
Purposes for Which We May Process Your Information
Direct Marketing
Cookies, Similar Technologies and Online Behavioral Advertising
What is the Lawful Basis for Processing Personal Information
What Information We Disclose to Third Parties
International Transfers of Information
Data Security
Data Accuracy
Data Minimization
Data Retention
What Can I Do to Control My Information?
Terms of Use
Contact Details
California Consumers
How this Privacy Policy May Change

Privacy Policy Overview

Policy Overview
This Policy explains how we may Process your information. This Policy maybe amended or updated from time to time, so please check it regularly for updates.

Bwiz Solutions, LLC, with its affiliates and its subsidiaries (collectively, “Bwiz Solutions”, “us”, “our” or “we”), owns, operates, or provides access to, several interactive websites, mobile and connected applications, and other online interactive features and services, including, but not limited to, emails, newsletters, chat areas, forums, communities, sweepstakes and contests (collectively “Services”).

This Privacy Policy applies to all information collected about you by Bwiz Solutions, regardless of how it is collected or stored, and describes, among other things, the types of information collected about you when you interact with the Services, how your information may be used, when your information may be disclosed, how you can control the use and disclosure of your information, and how your information is protected.

Except as otherwise noted in this Privacy Policy, Bwiz Solutions is a data controller (as that term is used under the EU General Data Protection Regulation (“GDPR”), which means that we decide how and why the information you provide to us is processed. Please contact us policies@bwizsolutions.com This Policy may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of your information, or changes in applicable law. We encourage you to read this Policy carefully, and to regularly check this page to review any changes we might make.

What Categories of Information We May Process

“Personal Information” means information that is about any individual, or from which any individual is directly or indirectly identifiable.

“Process”, “Processing” or “Processed” means anything that is done with any Personal Information, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

We may Process the following categories of Personal Information about you:
Personal details: your name; username or log in details; password; areas or topics of interest; and photograph (if you or another user posts a photo on the Service).
Demographic information: gender; age/date of birth; nationality; salutation; job title, company information, education, work experience and other professional information; and language preferences.
Contact details: postal address; telephone and/or mobile number; email address; and your public social media handles or profile(s).
Consent records: records of any consents you may have given, together with the date and time, means of consent and any related information (e.g., the subject matter of the consent).
Location information: location data that describes the precise geographic location of your device (“Precise Location Data”).
Employer details: where you interact with us in your capacity as an employee, the contact information of your employer (including name, address, telephone number and email address) to the extent relevant.
Views and opinions: any views and opinions that you or other users choose to send to us, or publicly post about us on social media platforms or in the Services, including on forums.
We also collect other kinds of information from you or other sources, which we refer to as “Other Information” in this Policy, which may include but is not limited to:
Information about your use of the Services, such as usage data and statistical information, which may be aggregated.
Browsing history including the websites or other services you visited before and after interacting with the Services.
Non-precise information about the approximate physical location (for example, at the city or zip code level) of a user’s computer or device derived from the IP address of such computer or device (“GeoIP Data”).
Device identification (“ID”), which is a distinctive number associated with a smartphone or similar handheld device, but is different than a hardware serial number.
Advertising ID, which is a unique, user-resettable identification number for advertising associated with a device (e.g., iOS uses the Identifier for Advertising (or “IDFA”) and Android uses Google Advertising ID).
Internet Protocol (“IP”) address, which is a unique string of numbers automatically assigned to your device whenever you access the Internet.
Internet connection means, such as internet service provider (“ISP”), mobile operator, WiFi connection, service set identifier (“SSID”), International Mobile Subscriber Identity (“IMSI”) and International Mobile Equipment Identity (“IMEI”).
Information collected through the use of cookies, eTags, Javascript, pixel tags, device ID tracking, anonymous identifiers and other technologies, including information collected using such methods and technologies about (i) your visits to, and interaction and engagement with, the Services, content and ads on third party websites, applications, platforms and other media channels (“Channels”), and (ii) your interaction with emails including the content and ads therein (collectively, “Online Data”).
Device type, settings and software used.
Log files, which may include IP addresses, browser type, ISP referring/exit pages, operating system, date/time stamps and/or clickstream data, including any clicks on customized links.
Web Beacons, which are electronic files that allow a website to count users who have visited that page or to access certain cookies.

Pixel Tags, also known as clear GIFs, beacons, spotlight tags or web bugs, which are a method for passing information from the user’s computer to a third party website.
Local Shared Objects, such as Flash cookies, and Local Storage, such as HTML5.
Mobile analytics to understand the functionality of our mobile applications and software on your phone.
Under certain circumstances and depending on applicable law, some of this Other Information may constitute Personal Information. Personal Information together with Other Information is hereinafter referred to as “User Information”.

Sensitive Personal Information

We do not collect or otherwise Process Personal Information about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, or any other information that may be deemed to be sensitive under GDPR (collectively, “Sensitive Personal Information”) in the ordinary course of our business. Where it becomes necessary to Process Sensitive Personal Information under GDPR, we would rely on one of the following legal bases:

Compliance with applicable law: We may Process your Sensitive Personal Information where the Processing is required or permitted by applicable law;
Detection and prevention of crime: We may Process your Sensitive Personal Information where the Processing is necessary for the detection or prevention of crime (including the prevention of fraud);
Establishment, exercise or defense of legal rights: We may Process your Sensitive Personal Information where the Processing is necessary for the establishment, exercise or defense of legal rights; or
Consent: We may Process your Sensitive Personal Information where we have, in accordance with applicable law, obtained your prior, express consent prior to Processing your Sensitive Personal Information.

How We Collect or Create Information

Collection of User Information: We may collect User Information about you from the following sources:
Data you provide: We may obtain your Personal Information when you provide it to us across our Services (e.g., where you sign up for emails, newsletters, bulletins, webinars or white papers; register for site membership or create a profile or account on any part of the Services; enter a sweepstakes, contest, competition or prize draw; receive promotional information by SMS text message; participate in surveys; perform search queries through the Services; contact us via email, telephone or by any other means; purchase a subscription, software license or product; or when you provide us with your business card, etc.).
Relationship data: We may collect or obtain your Personal Information in the ordinary course of our relationship with you (e.g., if you purchase a service from us).
Data you make public: We may collect or obtain your Personal Information that you clearly choose to make public, including via social media (e.g., we may collect information from your social media profile(s) if you make a public post about us) or through our chats, forums or communities on the Services.
Service data: We may collect or obtain your Personal Information when you visit, download, use or register to use any part of our Service.
Content and advertising information: If you choose to interact with any third party content or advertising on the Services or Channels, we may receive User Information about you from the relevant third party.
Third party information: We may collect or obtain your Personal Information from third parties who provide it to us. This may include offline channels such as through telephone or direct mail efforts; from customers, vendors, suppliers, third parties, commercially available or publicly-available sources (e.g., data brokers, data aggregators, public databases, etc.); third party affiliate network operators; referral sources; social network sites or services (e.g., Facebook, Twitter, LinkedIn, etc.). If you use a third party connection or log-in (e.g., Facebook Connect, Twitter, or Google+) to access the Services, create a
membership or profile on any part of the Services, access our content or forward our content to another person, platform or service, we may also receive your username or email address for those third party services or other information available about you or collected from you on those services.
Please note that Bwiz Solutions is not responsible for the information you volunteer about yourself in the discussions in certain public areas of the Services, such as forums, blogs, wikis, chat rooms, private messages, message boards or other publicly accessible interaction, or information that you choose to make public in your member profile or other areas of the Services that allow users to upload or post content. We discourage users from posting such Personal Information in this fashion. You can change your publicly available information at any time via your profile page. To request removal of your Personal Information from these areas, please contact us using our policies@bwizsolutions.com.

In some cases, we may not be able to remove your Personal Information, in which case we will let you know we are unable to do so and why.

This Privacy Policy does not cover the practices of third parties, including those that may disclose information to Bwiz Solutions.

Creation of User Information. We may also create User Information about you, such as records of your interactions with us and details of your purchase history, for internal administrative purposes and analysis. We may also combine data you have provided to us with data obtained from third parties such as social networks and other data collection entities.

Purposes for Which We May Process Your Information

The purposes for which we may Process User Information, subject to applicable law, include:
Provision of the Services to You: providing the Services to you from Bwiz Solutions or its partners including (i) offering of contests, as well as chat areas, forums and communities, (ii) posting of your personal testimonial alongside other endorsements, (iii) display of your personal reviews of products or services, (iv) allowing you to search for other website members using information you may already know about that member such as username, full name or gamer profile and identify users matching that criteria, (v) management of your account, and (vi) customer support and relationship management.
Offering and Improving the Services: operating and managing the Services for you; providing personalized content to you; communicating and interacting with you via the Services; identifying issues with the Services and planning improvements to or creating new Services; and notifying you of changes to any of our Services.
Surveys: engaging with you for the purposes of obtaining your views on our Services.
Communications: communicating with you via any means (including via email, telephone, text message, social media, post or in person) regarding news items and other information in which
you may be interested, subject to ensuring that such communications are provided to you in compliance with applicable law; maintaining and updating your contact information where appropriate; and obtaining your prior, opt-in consent where required. We may provide direct marketing to you as set out in Section 6 below.
Advertising: providing advertising based on your interests and interactions with the Services and Channels, including using User Information to serve you advertisements on the Services and Channels, as well as licensing segments of User Information to third parties. For further information, please see Section 7 below.
Audience Engagement: identification and development of audience engagement, advertising and promotional strategies on various platforms and channels, both within the Service and on Channels.
Lead Generation: business-to-business lead generation in the provision of leads to customers to improve customer’s target marketing campaigns and services through different strategies. This includes generating leads through phone calls and email newsletter marketing to drive you to content, such as white papers and webinars, offered by Bwiz Solutions whereupon your contact information will be shared with our customer.
B2BSignals Offering: providing a software product that offers customers to filter through a database of contacts by revenue, employee size, functional roles and more, that allows customers to find the right business-to-business leads to improve their marketing campaigns and services.
Marketing to Customers: We may market to current and prospective customers and their employees who have indicated an interest in doing business with, or have previously conducted business with, Bwiz Solutions in order to further generate and promote our business. Such efforts include sending marketing emails or conducting phone calls to drive the purchase of advertising, Online Data licensing, lead generation and other business services offered by Bwiz Solutions.
IT Administration: administration of Bwiz Solutions’ information technology systems; network and device administration; network and device security; implementing data security and information systems policies; compliance audits in relation to internal policies; identification and mitigation of fraudulent activity; and compliance with legal requirements.
Security: electronic security measures (including monitoring of login records and access details) to help mitigate the risk of and provide the ability to identify and rectify a security incident.
Investigations: detecting, investigating and preventing breaches of policy, and criminal offences, in accordance with applicable law.
Legal Proceedings: establishing, exercising and defending legal rights.
Legal Compliance: Subject to applicable law, we reserve the right to release information concerning any user of Services when we have grounds to believe that the user is in violation of our Terms of Use or other published guidelines or has engaged in (or we have grounds to believe is engaging in) any illegal activity, and to release information in response to court and governmental orders, other requests from government entities, civil subpoenas, discovery requests and otherwise as required by law or regulatory obligations. We also may release information about users when we believe in good faith that such release is in the interest of protecting the rights, property, safety or security of Bwiz Solutions, any of our users or the public, or to respond to an emergency

Direct Marketing

We may Process your User Information to contact you via email, telephone, direct mail, SMS or other methods of communication to provide you with information regarding the Services that may be of interest to you. We may send information to you regarding the Services, upcoming promotions and other information that may be of interest to you, using the contact details that you have provided to us and always in compliance with applicable law.

You may unsubscribe from our newsletter lists at any time by following the unsubscribe instructions included in every email we send. We will not send you any emails from a list you have selected to be unsubscribed from, but we may continue to contact you to the extent necessary for the purposes of any other Services you have requested or for additional emails you have signed up for. You may opt out of any telephone marketing by contacting us at the contact details set out in Section 17 below.

Cookies, Similar Technologies and Online Behavioral Advertising

Bwiz Solutions and its partners may use cookies and other tracking technologies to analyze trends, administer Services, track users’ movements around the Services and on third party sites, devices and applications, and to gather demographic information about our user base. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on the Services.

Please refer to our Cookie Policy for more information, including a more in-depth explanation of what cookies are, the different types of cookies used on the Services, and how to change or delete them.

Tracking technologies on the Services may be deployed by Bwiz Solutions and/or by our service providers or partners. Certain tracking technologies enable us to assign a unique identifier to you, and relate information about your use of the Services to other information about you, including your

User Information. We may match information collected from you through different means or at
different times and use such information along with offline and online information obtained from other sources (including from third parties), including, but not limited to, demographic information and updated contact information, for the purposes of learning more about you so we can provide you with relevant content and advertising.

When you receive email messages or newsletters from us, we may use web beacons, customized links, clear GIFs or similar technologies to determine whether the email has been opened and which links you click in order to provide you with more focused email communications or other information, and/or to aggregate that information with other data we collect to use for some or all of the purposes outlined in this Privacy Policy.

We and our partners (including but not limited to e-commerce partners, affiliates, and analytics providers) also may use technologies such as pixel tags, e-tags, IP addresses, Local Shared Objects, Local Storage, Flash cookies and HTML5 to analyze trends; administer the Services; collect and store information such as user settings, anonymous browser identifiers and video viewing history; supplement our server logs and other methods of traffic and response measurement; track users’ location and movements around the Services; gather demographic information about our user base; and to improve our understanding of traffic on the Services, visitor behavior, and responses to promotional campaigns. We may receive reports based on the use of these technologies by these third party companies on an individual and aggregated basis. For example, we may connect information about your IP address to known corporate or User Information and use the associated information related to aggregate content preferences to assist in our efforts to market services to you or the originating corporation(s). Various browsers may offer their own management tools for removing Local Storage.

We may use mobile analytics software to collect data and to better understand the functionality of our mobile software, devices and applications on your phone and other devices. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We may link this information to User Information.

Bwiz Solutions and/or certain third parties may collect information about you for online behavioral advertising (“OBA”) purposes in order for you to receive relevant interest-based advertising on the Services and on other websites, platforms and media channels. OBA is also referred to as interest-based advertising.

Bwiz Solutions displays ads on both the Services and on the Channels. We may use Online Data as well as other User Information to send you OBA. For example, if you read an article about a particular subject on the Services, we may use cookies from a vendor to later serve you an advertisement for a particular product or service related to the viewed article. These third party vendors may connect information about pages you visit on the Services with information about pages you visit on other Channels and show you advertising based on this combined information. These advertisements may appear when you are visiting a different section of the Services or on another Channel. Likewise, third party vendors may serve you advertisements when you visit the Services based on your interaction with the Services and other Channels.

What is the Lawful Basis for Processing Personal Information

In Processing your User Information in connection with the purposes set out in this Policy, we may rely on one or more of the following legal bases, depending on the circumstances:
Consent: We may Process your User Information where we have obtained your prior, express consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way);
Contractual necessity: We may Process your User Information where the Processing is necessary in connection with any contract that you may enter into with us;
Compliance with applicable law: We may Process your User Information where the Processing is required by applicable law;
Vital interests: We may Process your User Information where the Processing is necessary to protect the vital interests of any individual; or
Legitimate interests: We may Process your User Information where we have a legitimate interest in carrying out the Processing for the purpose of managing, operating or promoting our business, and that legitimate interest is not overridden by your interests, fundamental rights, or freedoms.
As described above, we have identified our lead generation services and how we market our business to our current and prospective customers as having a legitimate interest.

What Information We Disclose to Third Parties

We may disclose your User Information to other entities within the Company group, for legitimate business purposes (including operating the Services, and providing services to you), in accordance with applicable law. In addition, we may disclose your User Information to:
legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation;
outside professional advisors (such as accountants, auditors, or lawyers), subject to binding contractual obligations of confidentiality;
third party Processors (such as analytic providers; data centers; etc.), located anywhere in the world, subject to the requirements noted below in this Section 9;
any relevant party, law enforcement agency or court, to the extent necessary for the establishment, exercise or defense of legal rights;
any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including safeguarding against and the prevention of threats to public security;
any relevant third party acquirer(s), in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation);
any relevant third party provider, where our Services use third party advertising, plugins or content. If you choose to interact with any such advertising, plugins or content, information about your activities on the Services and Channels to provide you targeted advertising based upon your interests may be shared with the relevant third party provider. If you click or tap on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria;
any sponsors of contests, competitions, sweepstakes and prize draws, or white papers, webcasts or other downloads, the registration data for such events is to be used by us as part of User Information, and may be shared with the sponsor and others, subject to this Policy and the sponsor’s privacy policy. We may also share your information with third party vendors involved in the administration of such events. For contests, competitions, sweepstakes and prize draws, please read the official rules or terms and conditions carefully before you submit your information; and
to third parties whose practices are not covered by this Privacy Policy (e.g., third party providers of goods and services, marketing and advertising companies and agencies, content publishers and retailers).

For some of our Services, we may make some information, such as the name of our users, their mailing address, phone number, email address—and in certain circumstances their employer’s name, company size and other industry data—available on a rental or other basis (e.g., sale) to third party providers of goods and services, for example, when such information is provided in connection with webcasts, white papers or other sponsored downloads.

When you use a co-branded service (a service operated with a partner of Bwiz Solutions), or register or otherwise provide information on a co-branded site, you grant us permission to pass the collected information back to that partner, which may include third party service providers whose services are embedded into and/or appear within the Services;
With respect to surveys, in the event that responses are publicly disclosed, users will be notified at the time they take the survey. Otherwise we will disclose only aggregate information regarding its users’ responses in surveys to other participants in the survey. Where surveys allow users to submit written comments, and where Bwiz Solutions advises users of the possibility of such disclosure at the time they take the survey, Bwiz Solutions reserves the right to disclose any information provided by users, provided that no User Information identifying a specific user is disclosed.

Bwiz Solutions and some of our advertisers may use third party advertising service companies to serve advertisements, for OBA or otherwise, and perform related services when you interact with the Services. Often, these third party advertising companies employ cookies and other technologies to measure the effectiveness of website, app and email advertisements and to create a record of interaction with our content that they use in conjunction with their advertising which appears on other sites or applications, or for reporting website traffic, app use, statistics, advertisement data and/or other activities on the Services. We also engage third party providers to assist with the segmentation of this data.

We may also sell or transfer Online Data to certain third parties such as advertisers who will use this data to serve ads that they believe are relevant to your interests, and who agree to maintain the confidentiality of this information. Some of these third parties may combine the Online Data with their own data about you to form a more detailed picture.

We may engage third party providers to assist with the collection, storage and segmentation of Online Data and the providers are required to maintain the confidentiality of this information. These third party providers may collect User Information from our Services for their own purposes, including but not limited to monitoring fraud around the web.

We may also engage third parties for the purpose of recognizing our users and delivering interest-based content and advertisements to them. We may share your User Information with our partners such as your name, postal address, email, or other identifier. Our partners may also: (i) collect information directly from your device, such as your IP address, device ID, advertising ID, and information about your browser or operating system; (ii) combine User Information about you received from Bwiz Solutions with information about you from other sites or services; and (iii) place or recognize a unique cookie on your browser.

If we engage a third-party Processor to Process your User Information, the Processor will be subject to binding contractual obligations to: (i) only Process the User Information in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the User Information; together with any additional requirements under applicable law.
The Services contain links to other sites or partners whose information practices may be different from ours. You should consult the privacy policy of these third parties to learn how your privacy is protected.

International Transfers of Information

Because of the international nature of our business, we may need to transfer your User Information within the Bwiz Solutions and its affiliates, and to third parties as noted in Section 9 above, in connection with the purposes set out in this Policy. For this reason, we may transfer your User Information to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located.

Bwiz Solutions participate in compliance with the E.U.-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. Bwiz Solutions is committed to subjecting all Personal Information received from European Union (E.U.) member countries and Switzerland, in reliance on the Privacy Shield Framework, to the Framework’s applicable principles. To learn more about the Privacy Shield Framework, please visit the U.S. Department of Commerce’s Privacy Shield List. Bwiz Solutions is responsible for the processing of Personal Information it receives under the Privacy Shield Framework and subsequent transfers to a third party acting as an agent on its behalf. Bwiz Solutions complies with the Privacy Shield principles for all onward transfers of Personal Information from the E.U. and Switzerland, including the onward transfer liability provisions. With respect to Personal Information received or transferred pursuant to the Privacy Shield Framework, Bwiz Solutions is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Bwiz Solutions may be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. If you are a European individual with a privacy related complaint, concern or question about Bwiz Solutions’ privacy practices, please contact us through our policies@bwizsolutions.com . Under certain conditions, more fully described on the Privacy Shield website, European individuals may invoke binding arbitration when other dispute resolution procedures have been exhausted.

Where we transfer your Personal Information from the EEA to recipients located outside the EEA who are not in a jurisdiction that has been formally designated by the European Commission as providing an adequate level of protection for Personal Information, we do so on the basis of standard contractual clauses.

Please note that when you transfer any Personal Information directly to a Company entity established outside the EEA, we are not responsible for that transfer of your Personal Information. We will nevertheless Process your Personal Information, from the point at which we receive the data, in accordance with the provisions of this Privacy Policy.

Bwiz Solutions privacy practices described in this Privacy Policy comply with the Asia-Pacific Economic Cooperation (“APEC”) Cross Border Privacy Rules System. To learn more about this program, please click here.

Please note that we may use data collected by a third party operator/licensee of localized versions or editions of Services.

Data Security

We have implemented appropriate technical and organizational security measures designed to protect your User Information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized forms of Processing, in accordance with applicable law. In certain instances we may use Secure Sockets Layer encryption and/or transfer certain User Information in a non-human readable format to provide protection. However, we cannot guarantee there will not be a breach, and we are not responsible for any breach of security or for the actions of any third parties.

Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement reasonable measures to protect your information, we cannot guarantee the security of your data transmitted to us using the internet. Any such transmission is at your own risk and you are responsible for ensuring that any Personal Information that you send to us are sent securely.

Data Network map

Data Accuracy

We take every reasonable step to ensure that your User Information that we Process is accurate and, where necessary, kept up to date, and any of your User Information that we Process that you inform us is inaccurate (having regard to the purposes for which they are Processed) is erased or rectified.

Data Minimization

We take every reasonable step to ensure that your User Information that we Process is limited to the User Information reasonably necessary in connection with the purposes set out in this Policy or as required to provide you services or access to the Services.

Data Retention

We take every reasonable step to ensure that your User Information is only Processed for the minimum period necessary for the purposes set out in this Policy. The criteria for determining the duration for which we will keep your User Information are as follows: we will retain copies of your User Information in a form that permits identification only for as long as is necessary in connection with the purposes set out in this Policy, unless applicable law requires a longer retention period. Unless there is a specific legal requirement for us to keep the information, we plan to retain it for no longer than is necessary to fulfill a legitimate business need.

Except as may be set forth in this Privacy Policy, Online Data related to OBA is retained by Bwiz Solutions for not more than 180 days after which it shall expire. However, the 180 day period may commence again if the same user subsequently visits or interacts with an ad, email, the Services or a Channel.

What Can I Do to Control My Information?

You may directly take steps to change your preferences as follows:
Access to Your Personal Information. Upon request Bwiz Solutions will provide you with information about whether we hold any of your personal information. You may access, correct, or request deletion of your personal information by logging into your account or contacting us through our policies@bwizsolutions.com. We will respond to your request within a reasonable timeframe.

Your Newsletter and Email Subscriptions. You can opt out or unsubscribe to a newsletter or other email list at any time by following the instructions at the end of the newsletters or emails you receive. Please allow five to ten business days for changes to take effect. On some Services, member service-related communications are an integral part of such Services to which you subscribe and you may continue to receive emails as part of that particular portion of the Services unless you cancel your account, even if you opt out of the newsletters or email list. If you have provided more than one email address to us, you may continue to be contacted unless you request to unsubscribe each email address you have provided.

Push Notifications. We send you push notifications from time-to-time in order to update you about any events or promotions that we may be running. If you no longer wish to receive these types of communications, you may turn them off at the device level. To ensure you receive proper notifications, we will need to collect certain information about your device such as operating system and user identification information.

OBA. Bwiz Solutions uses third party assurance platforms to comply with the DAA principles. Bwiz Solutions strives to adhere to the self-regulatory organization principles for the DAA (US), the DAAC (Canada) and the EDAA (EU). Online ads on the Services using Online Data are delivered with the DAA Ad Marker Icon, which helps users understand how their data is being used and provides choices for users who want more control. This icon is also on each of our web pages and applications where Online Data is collected that will be used for OBA purposes.

European Union and Switzerland residents should visit the European DAA by clicking here.
Canadian residents should visit the DAA of Canada by clicking here.
U.S. residents and residents of all other countries or territories not listed above can click here for the DAA site to learn more about the use of cookies, your opt-out choices, and more.
Cookies and Pixel Tags. You may stop or restrict cookies and pixel tags on your computer or purge cookies from your browser by adjusting your web browser preferences. However, if you “turn off,” purge, or disable cookies or pixel tags, although you may still use the Services, you may not be able to use all of the features, functions, or services available on the Services.

Location Based Services. You may opt-out of having your Precise Location Data collected by Bwiz Solutions at any time by editing the appropriate setting on your mobile device (which is usually located in the Settings area of your device).
California Residents. In accordance with the California Online Privacy Protection Act, we may collect Personal Information about your online activities when you use the Services. While we give our users many avenues to opt out of providing Personal Information, we do not respond to Web browsers’ “do not track” signals. California’s “Shine the Light” law, Civil Code Section 1798.83, permits our users who are California residents to periodically request and obtain certain information about any Personal Information disclosed to third parties for direct marketing purposes. If you are a California resident and wish to make such a request or if you wish for us to refrain from gathering your Personal Information, please submit your request in writing to the contact details set out in Section 17 below.

EU Residents. GDPR provides certain rights for EU residents. You may decline to share certain information with us, in which case we may not be able to provide some of the features and functionality of the Services. These rights include, in accordance with applicable law, the right to object to or request the restriction of processing of your information, and to request access to, rectification, erasure and portability of your own information. Where we process your information on the basis of your consent, you have the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any Processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the Processing of your Personal Information in reliance upon any other available legal bases). Requests should be submitted by contacting us using the policies@bwizsolutions.com .
If you are an EU resident and have any unresolved privacy concern, you have the right to contact the appropriate EU Supervisory Authority and lodge a complaint.

Terms of Use

For more information concerning your use of the Services, please visit the Bwiz Solutions Terms of Use. The Bwiz Solutions Terms of Use is incorporated by reference into this Privacy Policy.
We recommend that you review our Terms of Use regularly, in order to review any changes we might make from time to time.

Contact Details

If you have any comments, questions or concerns about any of the information in this Policy, or any other issues relating to the Processing of User Information carried out by us, or on our behalf, please contact:
Bwiz Solutions
Attention: Legal Department
legal@bwizsolutions.com

California Consumers

Right to Know About Information Collected, Disclosed or Sold

You have the right to request that we disclose what personal information we collect, use, disclose, and sell. To submit a verifiable request, please visit our bwizsolutions.com/policies or email policies@bwizsolutions.com

Collection of Personal Information

We urge you to come back to this web page and review this Privacy Policy regularly so that you remain aware of the terms and conditions that apply to you.

you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your pers, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please Contact us.

NO FEE USUALLY REQUIRED

WHAT WE MAY NEED FROM YOU

TIME LIMIT TO RESPOND